Demurrer to OAG Petition for Writ of Quo Warranto

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COMMONWEALTH OF VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA COMMONWEALTH OF VIRGINIA, on behalf of Karen Grane, Esq., Jason McCandless, Esq., Ben Kendrick, Esq. and other Bar members of Arlington County; by employees of the Office of Attorney General for Virginia: Mr. John D. Gilbody, Assistant Attorney General Mr. Peter R. Messitt, Senior Assistant Attorney General Mr. Wesley G. Russell, Jr., Deputy Attorney General Mr. Kenneth T. Cuccinelli, II, Attorney General Petitioners v. JAMES RENWICK MANSHIP, SR. Chaplain, Amos 5:15 Project, God and Country Foundation; on behalf of the Rights of all Citizens of Virginia Respondent DEMURRER PETITION FOR WRIT OF QUO WARRANTO TO: The Honorable Servants, Judges of the Circuit Court of the City of Alexandria, Virginia Citizen of Virginia James Renwick Manship, Sr., on behalf of the Rights of all Citizens of Virginia, hereby files this DEMURRER to the baseless Office of Attorney General’s Petition for Writ of Quo Warranto transmitted by UPS Ground Delivery on July 6, 2012, and received by Chaplain Manship many weeks later, and neither the Petition nor the Summons to appear in Court were ever served by Alexandria Sheriff’s office to Chaplain Manship. 1. The Legal Information Institute of Cornell University Law School defines Demurrer as: A defense asserting that even if all the factual allegations in a complaint are true, they are insucient to establish a valid cause of action .

description

Bar corruption, AG cover-up of child abuse, court corruption

Transcript of Demurrer to OAG Petition for Writ of Quo Warranto

Page 1: Demurrer to OAG Petition for Writ of Quo Warranto

COMMONWEALTH OF VIRGINIA:

IN THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA

COMMONWEALTH OF VIRGINIA, on behalf of Karen Grane, Esq., Jason McCandless, Esq., Ben Kendrick, Esq. and other Bar members of Arlington County; by employees of the Office of Attorney General for Virginia: Mr. John D. Gilbody, Assistant Attorney General Mr. Peter R. Messitt, Senior Assistant Attorney General Mr. Wesley G. Russell, Jr., Deputy Attorney General Mr. Kenneth T. Cuccinelli, II, Attorney General Petitioners

v.

JAMES RENWICK MANSHIP, SR. Chaplain, Amos 5:15 Project, God and Country Foundation; on behalf of the Rights of all Citizens of Virginia Respondent

DEMURRER

PETITION FOR WRIT OF QUO WARRANTO

TO: The Honorable Servants, Judges of the Circuit Court of the City of Alexandria, Virginia

Citizen of Virginia James Renwick Manship, Sr., on behalf of the Rights of all Citizens of

Virginia, hereby files this DEMURRER to the baseless Office of Attorney General’s Petition for

Writ of Quo Warranto transmitted by UPS Ground Delivery on July 6, 2012, and received by

Chaplain Manship many weeks later, and neither the Petition nor the Summons to appear in

Court were ever served by Alexandria Sheriff’s office to Chaplain Manship.

1. The Legal Information Institute of Cornell University Law School defines Demurrer as:

A defense asserting that even if all the factual allegations in a complaint are true, they are insufficient to establish a valid cause of action.

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2. Other legal information sites state that the Demurrer is still a valid legal pleading in

California and Virginia. This pleading is filed in Virginia, so a Demurrer is still valid.

3. Other legal information sites state that before a Demurrer may be filed, a letter to the

opposing party asking for their pleading to be withdrawn must be done. Chaplain Manship met

this requirement with his letter of 31 August in the Year of Our Lord Jesus 2012 to Mr. John D.

Gilbody, Assistant Attorney General, Mr. Peter R. Messitt, Senior Assistant Attorney General,

Mr. Wesley G. Russell, Jr., Deputy Attorney General, and Mr. Kenneth T. Cuccinelli, II, Attorney

General, that was acknowledged receipt and denied by the letter of Mr. John D. Gilbody,

Assistant Attorney General of September 10, 2012, received by Chaplain Manship on 19

September in the Year of Our Lord Jesus 2012 at his Mount Vernon post office box.

4. The statements made in the pleading by the Office of the Attorney General may be in

some instances true, in others misleading, and still others are out and out false statements, even if

based on false statements received from named and other Bar members of Arlington County,

contrary to Mr. Gilbody’s signed verification statement on page 5 of the Petition.

5. Even if all true, the statements in the Petition by Virginia’s Office of Attorney General

(OAG) do not establish a cause of action. Quo Warranto suggests “What warrant?”, in this case

the OAG assumes that Chaplain Manship is holding, or acting as if he holds a warrant for an

office in the government. In truth, as a former Navy officer and as a Major in the Civil Air

Patrol, Chaplain Manship does hold a warrant, a commission, as an officer in the government.

6. Granted, the OAG Petition is not directed toward any “warrant” as an officer of the

government, rather the “warrant” of the government for the license to practice law in the

Commonwealth of Virginia. The Exhibits provided by the OAG prove that in no case has

Chaplain Manship claimed or implied he has a license from the Bar to practice law in Virginia.

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7. With no claim, or misrepresentation by Chaplain Manship, that he is licensed by an

agency of the Virginia supreme Court, namely the Virginia State Bar, there is no basis for the

OAG Petition that assumes a falsehood, hostile to the First Amendment Rights of this

Constitution for the United States of America due to Chaplain Manship and all Virginians.

8. In addition, the OAG Petition seriously omits significant past court cases and quasi-

judicial actions of the Virginia State Bar with results not unfavorable to Chaplain Manship.

9. Further, the OAG Petition falsely applies the Virginia supreme Court Rules. They define

four areas of action that combine to comprise the Practice of Law. The VsC rules mention other

aspects of VsC rules that validate Chaplain Manship in his conduct of the Jesus-like ministry as

an advocate and counselor. The OAG pleading is deficient in this and many other ways.

10. More egregious, by the Petition the OAG acts as though an ostrich with its head in the

sand about pertinent legislation by the Virginia General Assembly, the same representatives of

the Sovereign who are We the People, from which the “warrant” of the OAG and Virginia State

Bar lawyers derive. The OAG Petition is factually deficient or intentionally misleading, or both.

11. Per OAG Petition paragraph 16, the OAG Petition is factually false because it again

assumes wrongly. The Respondent has a legal physical address in the jurisdiction of Alexandria,

but is not a resident of Alexandria, as judged by the voting residence, that the OAG with its

considerable resources, could have pre-determined, if wishing to be a responsible litigant.

12. Most egregious, the Bar member employees of the OAG in whose name the Petition was

filed, and who take an Oath to protect and defend this Constitution for the United States of

America against all enemies foreign and domestic, or some similar Oath, instead run rough-shod

over the Rights of Citizens of Virginia guaranteed by the First Amendment ratified to this

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Constitution for the United States of America, the free exercise of religion (like Jesus as an

advocate and counselor), the freedom of speech (both for oneself and for others), freedom of the

press (to print, or have printed articles that expose the corruption of the Arlington Courts and

members of the Arlington Bar); the right to peaceably to assemble (that includes to assist fellow

citizens when officers of government such as Bar members have acted as tyrants hostile to the

Rights of Liberty and Life of the sovereign Citizens); and to petition the Government for redress

of grievances (with the logical implication that the officers in government will respond in a

proper and reasonable way, such that in this case, “licensed officers” of the government of

Arlington have done NOTHING to act in a proper manner about the unprovoked, BLOODY

ASSAULT of a 12 year old girl, Ashlie Mae O’Brien, by a Deputy Sheriff Neptuno Mendez-

Ventura in the Arlington Court House, witnessed and reported by Chaplain Manship to numerous

taxpayer paid employees of the Commonwealth of Virginia, who have been derelict in their duty

in protecting a defenseless child, and protecting the Rights of All Virginia Citizens in Arlington

Courts, that are a cesspool of corruption, and also fraud, such as the Padded, or Inflated, or

Exaggerated Expense Vouchers of Arlington Bar member Karen Grane, a court designated

Guardian Ad Litem, and then covered up by another Arlington Bar member, G. Varoutsos.)

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.

13. WHEREFORE, for the above reasons and many more, this Demurrer must be granted,

preferably with Prejudice against the OAG, the Virginia State Bar and Arlington County, so to

stop the taxpayer paid employees of the Office of the Attorney General, and various taxpayer

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paid employees of Arlington, and indirectly taxpayer paid employees of the Virginia State Bar

from any further malicious or frivolous legal actions that consume and waste the scarce resources

of time and money of the respondent, Chaplain James Renwick Manship, Sr., a Citizen acting

within the laws passed by the General Assembly.

James Renwick Manship, Sr., Chaplain

I, James Renwick Manship, Sr., Chaplain of the Amos 5:15 Project “Hate evil and love the good.

Remodel your courts into True halls of Justice.” of the God and Country Foundation, declare

upon information and belief that the statements contained in the foregoing Demurrer to the

Office of Attorney General Petition for Writ of Quo Warranto are true.

James Renwick Manship, Sr., Chaplain

CERTIFICATE OF SERVICE

I certify that on this 21st day of September in the Year of Our Lord Jesus 2012, I mailed by first

class mail, postage prepaid, a true copy of the foregoing to:

Mr. John D. Gilbody Assistant Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219

James Renwick Manship, Sr., Chaplain